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Financial Services Law Insights and Observations

CFPB releases annual HMDA and TILA adjustments

Federal Issues CFPB HMDA TILA Regulation C Regulation Z

Federal Issues

On December 22, the CFPB announced final rules adjusting the asset-size thresholds under HMDA (Regulation C) and TILA (Regulation Z). Both rules took effect January 1.

Under HMDA, institutions with assets below certain dollar thresholds are exempt from the collection and reporting requirements. The final rule increases the asset-size exemption threshold for banks, savings associations, and credit unions from $47 million to $48 million, thereby exempting institutions with assets of $48 million or less as of December 31, from collecting and reporting HMDA data in 2021.

TILA exempts certain entities from the requirement to establish escrow accounts when originating higher-priced mortgage loans (HPMLs), including entities with assets below the asset-size threshold established by the CFPB. The final rule increases this asset-size exemption threshold from $2.202 billion to $2.230 billion, thereby exempting creditors with assets of $2.230 billion or less as of December 31, from the requirement to establish escrow accounts for HPMLs in 2021.

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